Mandatory technical requirements for paints published in Vietnam 
On December 21, 2020, the Ministry of Industry and Trade of Vietnam released the Circular No. 51/2020/TT-BCT on Promulgating the National Technical Regulation QCVN 8:2020/BCT on Limiting Lead Content in Paints. This technical regulation stipulates technical requirements, test methods, and management rules for lead contained in paints that are manufactured in, imported to, traded in Vietnam. The types and HS codes of regulated paints are given in Annex A of this technical regulation. This technical regulation will enter into force on January 1, 2022.
http://cuchoachat.gov.vn/default.aspx?page=legal&do=detail&category_id=2&id=83
Technical requirements
Lead content in paint products must not exceed the limits shown in this table:
| No. | Time of enforcement | Upper limit for lead content (ppm) |
| 1 | Within 5 years of the effective date of this technical regulation | ≤ 600 |
| 2 | After 5 years of the effective date of this technical regulation | ≤ 90 |
Test method
The sampling must be performed with a method prescribed in TCVN 2090: 2015 (ISO 15528: 2013) “Paints, varnishes and raw materials for paints and varnishes- Sampling.” The content must be measured pursuant to CPSC-CH-E1003-09-01 “Standard operating Procedure for Determining Lead (Pb) in Paint and Other Similar Surface Coatings, February 25, 2011.”
Label content
Label contents for lead containing paints must follow the Decree No. 43/2017/ND-CP on Goods Labeling and other related regulations. Furthermore, labels of paint products listed in Annex A of this technical regulation (reproduced below) must indicate lead content.
|
No. |
Paint types |
HS codes |
| 1 | Paint products based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a non-aqueous medium | 3208.10.90
3208.20.90 3208.90.90 |
| 2 | Paint products based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in an aqueous medium | 3209.10.40
3209.10.90 3209.10.00 |
| 3 | Other paints, watercolor paint prepared for leather finishing | 3210.00.20
3210.00.30 3210.00.99 |
Management rules
For paint products specified in Annex A of this technical regulation, declaration of conformity to this technical regulation is mandatory before any use and distribution in Vietnam. The declaration of conformity must be made in accordance with the provision of Article 11, Paragraph 2 of Circular 36/2019/TT-BCT on Quality Management of Products and Goods under the Ministry of Industry and Trade’s Responsibility. The conformity assessment methods shall be as follows.
- For imported paint products: Sampling tests, product lot assessments, etc. shall be performed in accordance with the Circular 28/2012/TT-BKHCN and Annex II, Item I (Method 1) of the Circular 02/2017/TT-BKHCN.
- For domestically manufactured paint products: Sampling tests, product lot assessments, etc. shall be performed in accordance with the Circular 28/2012/TT-BKHCN and Annex II, Item V (Method 5) of the Circular 02/2017/TT-BKHCN.
In addition, the conformity symbol mark (shown below) must be affixed pursuant to the Circular 28/2012/TT-BKHCN before any distribution of regulated products in the market.
